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INCOME TAXES
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
The income tax provision differed from amounts computed at the statutory federal income tax rate and consisted of the following significant components (in millions):
202420232022
Income tax provision at statutory rate$875 $711 $208 
State income tax provision, net of federal income tax benefit56 46 13 
Nondeductible employee meals16 15 12 
Nondeductible transportation fringe benefit16 13 10 
Valuation allowance29 (21)(10)
Other, net27 5 20 
Income tax expense$1,019 $769 $253 
Current$84 $13 $5 
Deferred935 756 248 
Income tax expense$1,019 $769 $253 
Temporary differences and carryforwards that give rise to deferred tax assets and liabilities at December 31, 2024 and 2023 were as follows (in millions):
 UALUnited
2024202320242023
Deferred income tax asset (liability):
Federal and state net operating loss ("NOL") carryforwards$2,149 $2,644 $2,119 $2,616 
Deferred revenue1,865 1,845 1,865 1,845 
Employee benefits, including pension, postretirement and medical 608 695 608 695 
Operating lease liabilities1,110 1,134 1,110 1,134 
Other financial liabilities517 414 517 414 
Interest expense carryforward467 579 467 579 
Other565 575 565 575 
Less: Valuation allowance(208)(179)(208)(179)
Total deferred tax assets $7,073 $7,707 $7,043 $7,679 
Depreciation$(7,171)$(6,782)$(7,171)$(6,782)
Operating lease right-of-use asset(863)(887)(863)(887)
Intangibles(619)(632)(619)(632)
Total deferred tax liabilities$(8,653)$(8,301)$(8,653)$(8,301)
Net deferred tax asset (liability)$(1,580)$(594)$(1,610)$(622)

United and its domestic consolidated subsidiaries file a consolidated federal income tax return with UAL. Under an intercompany tax allocation policy, United and its subsidiaries compute, record and pay UAL for their own tax liabilities as if they were separate companies filing separate returns. In determining their own tax liabilities, United and each of its subsidiaries take into account all tax credits or benefits generated and utilized as separate companies and they are each compensated for the aforementioned tax benefits on an annual basis.
The Company's federal and state NOL and tax credit carryforwards relate to prior years' NOLs and credits, which may be used to reduce tax liabilities in future years. These tax benefits are mostly attributable to federal pre-tax NOL carryforwards of $9.7 billion ($2.0 billion tax effected) for UAL. If not utilized, $0.1 billion of these federal pre-tax NOLs will expire in 2029. The remaining $9.6 billion of NOLs has no expiration date. State pre-tax NOLs of $3.0 billion ($0.2 billion tax effected) expire over a 1 to 20-year period. State tax credits of $58 million will expire over a 1 to 15-year period.
As of December 31, 2024, the Company has recorded $179 million of valuation allowance against its capital loss deferred tax assets. Capital losses have a limited carryforward period of five years, and they can be utilized only to the extent of capital gains. The Company does not anticipate generating sufficient capital gains to utilize the losses before they expire, therefore, a valuation allowance is necessary as of December 31, 2024. Additionally, the Company recorded a valuation allowance of $29 million on certain state deferred tax assets primarily due to state NOLs that have short expiration periods.
The Company's unrecognized tax benefits related to uncertain tax positions were $70 million, $66 million and $58 million at December 31, 2024, 2023 and 2022, respectively. All of the uncertain tax positions would affect the Company's effective tax rate if recognized. The changes in unrecognized tax benefits relating to settlements with taxing authorities, unrecognized tax benefits as a result of tax positions taken during a prior period and unrecognized tax benefits relating from a lapse of the statute of limitations were immaterial during 2024, 2023 and 2022. The Company does not expect significant increases or decreases in their unrecognized tax benefits within the next 12 months. There are no material amounts included in the balance at December 31, 2024 for tax positions for which the ultimate deductibility is highly certain but for which there is uncertainty about the timing of such deductibility.
The Company's federal income tax returns for tax years after 2000 remain subject to examination by the Internal Revenue Service and state taxing jurisdictions.